Question
X Corporation has 100 shares outstanding: 60 of which are owned by Ivan and 40 of which are owned by Flo. It also has the
X Corporation has 100 shares outstanding: 60 of which are owned by Ivan and 40 of which are owned by Flo. It also has the following assets that it distributes in complete liquidation:
Gainacre: basis of $100,000 and fair market value of $400,000
Lossacre: basis of ??? and fair market value of $400,000
Cash of $200,000
Ivan and Flo are unrelated individuals.
X corporation received Lossacre four years ago in a Section 351 transaction at a time when the contributing shareholder had a basis in Lossacre of $800,000 and the fair market value of Lossacre was $600,000. No elections were made at the time Lossacre was contributed.
If X corporation distributes each of its assets to Ivan and Flo as tenants-in-common in proportion to their stock interests, meaning Ivan takes a 60% interest in each asset while Flo takes a 40% interest, then:
a. | X corporation will realize a $400,000 loss on Lossacre and recognize $400,000 of it. | |
b. | X corporation will realize a $200,000 loss on Lossacre and recognize $200,000 of it. | |
c. | X corporation will realize a $200,000 loss on Lossacre and recognize $0 of it. | |
d. | X corporation will realize a $400,000 loss on Lossacre and recognize $0 of it |
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